MFN treaty benefits require specific domestic notification, leaving tax refund interest taxable at the Netherlands treaty interest rate.

MFN treaty benefits require specific domestic notification, leaving tax refund interest taxable at the Netherlands treaty interest rate. https://www.taxtmi.com/highlights?id=103911 MFN-based treaty benefits under the India-Netherlands DTAA require a notification under section 90(1) for domestic enforcement. Notification No. S.O. 693(E) reduced the Article 11(2) interest tax rate to 10 per cent for beneficial owners but did not incorporate the nil-rate exemptions available under the India-USA or India-Italy DTAAs. Interest on income-tax refunds under section 244A therefore remained taxable at the notified treaty rate, and the nil-rate claim was rejected. Eligible tax deducted at source credit remained available against the refund-interest income. en-us Fri, 18 Sep 2026 07:31:58 +0530 Fri, 18 Sep 2026 07:32:01 +0530 TaxTMI RSS Generator MFN treaty benefits require specific domestic notification, leaving tax refund interest taxable at the Netherlands treaty interest rate. https://www.taxtmi.com/highlights?id=103911 MFN-based treaty benefits under the India-Netherlands DTAA require a notification under section 90(1) for domestic enforcement. Notification No. S.O. 693(E) reduced the Article 11(2) interest tax rate to 10 per cent for beneficial owners but did not incorporate the nil-rate exemptions available under the India-USA or India-Italy DTAAs. Interest on income-tax refunds under section 244A therefore remained taxable at the notified treaty rate, and the nil-rate claim was rejected. Eligible tax deducted at source credit remained available against the refund-interest income. Highlights Income Tax Fri, 18 Sep 2026 07:31:58 +0530 https://www.taxtmi.com/highlights?id=103911